SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 11, 2025

Timothy Kraus
Senior Vice President and Chief Financial Officer
Dana Inc.
3939 Technology Drive
Maumee, OH 43537

 Re: Dana Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Form 8-K Furnished February 20, 2025
 File No. 001-01063
Dear Timothy Kraus:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2024
Note 1. Organization and Summary of Significant Accounting Policies
Supplier finance programs, page 38

1. We note that you participate in supplier finance programs whereby
certain suppliers
 may sell their right to your payment obligations to participating
financial institutions.
 Please provide the related disclosures set forth in ASC 405-50-50-3.
Form 8-K Furnished February 20, 2025
Exhibit 99.1, page 1

2. We note that you present Adjusted EBITDA margin without presenting a
comparative
 GAAP measure. Please revise future filings to present the GAAP measure,
which
 appears to be net income (loss) margin, with equal or greater
prominence. Refer to
 Item 10(e)(1)(i)(A) of Regulation S-K and Questions 102.10(a) of the
Compliance and
 Disclosure Interpretations on Non-GAAP Financial Measures ("Non-
 GAAP C&DI's").
 March 11, 2025
Page 2

3. For each non-GAAP measure, please ensure you present the most directly
comparable
 GAAP measure with equal or greater prominence. Refer to instruction 2 to
Item 2.02
 of Form 8-K, Item 10(e)(1)(i)(A) of Regulation S-K, and Question
102.10(a)-(b) of
 the Non-GAAP C&DI's. We note that you present free cash flow in the
introductory
 bullets without referencing operating cash flows, that you discuss
Adjusted EBITDA
 on pages 1 and 2 prior to a discussion of GAAP net income (loss), and
that certain
 non-GAAP reconciliations begin with a non-GAAP measure, such as total
Segment
 EBITDA, instead of the GAAP measure. Apply this comment to the earnings
 conference call slides included in your earnings releases, including
your disclosures
 on slides 4, 8-12, and 14-15.
4. We note that you present Segment EBITDA on a consolidated and segment
basis.
 Athough Segment EBITDA on a segment basis is a disclosure required by
ASC 280 in
 the notes to the financial statements, the presentation on a
consolidated basis outside
 of the segment footnote is a non-GAAP measure. Please revise to properly
identify
 consolidated Segment EBITDA as a non-GAAP measure and ensure that you
provide
 all related disclosures required by Item 10(e) of Regulation S-K.
 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact Andrew Blume at 202-551-3254 or Kevin Woody at
202-551-3629
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>